Search for HIPAA compliant telehealth platforms and you'll mostly find ranked lists. A ranking can't tell you whether a tool fits your practice, because no platform is HIPAA compliant on its own. HHS doesn't certify software, and the companies say so themselves: Google notes that HHS "doesn't offer a certification program for HIPAA compliance" (Google), and Microsoft says that using its services "doesn't on its own achieve HIPAA compliance" (Microsoft). A platform supports your compliance by signing a Business Associate Agreement (BAA) and giving you the right safeguards. Your telehealth is compliant when that agreement is in place and you set up and use the tool with care.
This guide gives you what you need to judge any option yourself: what HIPAA actually asks of a video platform, a checklist for comparing telehealth platforms for therapists, 13 questions you can email to any vendor, a test session to run before your first client, and the three kinds of platforms therapists choose between, described from each company's own documentation. We don't rank named products. At the end you'll see how TranqBay handles video sessions, since it is one of the options.
What "HIPAA compliant" means for a telehealth platform
HIPAA has no official list of video apps you may use. It has rules for you, if you are a covered entity, and for the vendors who handle protected health information (PHI) for you, called business associates. In practice, a telehealth platform is fit for HIPAA work when five things are true.
1The vendor signs a Business Associate Agreement
This is the line HHS draws most clearly. Its telehealth site says covered providers "must use technology vendors that comply with the HIPAA Rules and will enter into HIPAA business associate agreements in connection with the provision of their video communication products or other remote communication technologies for telehealth" (telehealth.hhs.gov).
A BAA isn't a badge. It's a contract with required terms. Under 45 CFR 164.504(e), the vendor must agree, among other things, to:
- use and disclose PHI only as the contract allows or the law requires;
- use appropriate safeguards and follow the Security Rule for electronic PHI;
- report to you any use or disclosure the contract doesn't allow, including breaches;
- make sure its own subcontractors that handle PHI agree to the same restrictions;
- help you meet clients' rights to access, amend and get an accounting of their records;
- return or destroy PHI when the contract ends, where that is feasible.
HHS publishes sample BAA provisions if you want to compare a vendor's wording with the standard. Vendors offer their BAAs in different ways: accepted online in an admin console, generated in account settings, sent on request, or built into the terms of service. Whatever the method, keep a copy or a dated screenshot with your practice records.
You may hear that a video service is "just a conduit" and doesn't need a BAA. HHS's conduit idea covers services that only transmit information, like a phone company carrying a call. Its audio-only telehealth guidance says a covered entity "must enter into a BAA with a vendor that is more than a mere conduit for PHI," and gives the example of an app that stores recordings or transcripts in its cloud. Video platforms usually hold accounts, schedules, chat, logs or recordings too. Don't build your compliance on the conduit exception; use a vendor that signs a BAA.
2Encryption in transit, and at rest for anything stored
The Security Rule's transmission security standard asks you to "guard against unauthorized access to electronic protected health information that is being transmitted over an electronic communications network" (45 CFR 164.312(e)). Encryption is listed as "addressable," which doesn't mean optional. Under 45 CFR 164.306(d)(3) you must assess whether it is reasonable and appropriate, and either implement it or document why not and use an equivalent measure. For video over the internet, it's hard to make a case against encryption in transit. Anything the platform stores, such as recordings, chat logs or uploaded files, should be encrypted at rest as well.
"End-to-end encryption" is a narrower claim: only the participants' devices can decrypt the call, not the vendor's servers. HIPAA doesn't name it as a requirement. On some platforms it's a separate mode that switches off features such as cloud recording, so if a vendor uses the phrase, ask exactly what it covers and when it applies.
HHS published a proposed update to the Security Rule on January 6, 2025 that would, among other changes, make encryption of electronic PHI required rather than addressable. As of this writing it hasn't been finalized, so the current rule applies.
3Access controls you can actually use
The technical safeguards in 164.312 include unique user identification (required), automatic logoff (addressable) and procedures to verify that a person seeking access "is the one claimed." On a telehealth platform that means:
- every clinician and staff member has their own login, never a shared one;
- two-step sign-in is available and switched on;
- sessions sign out after a period of inactivity;
- you can remove someone's access the day they leave.
Access also works at the level of each session: a waiting room or admit button so nobody enters until you let them in, and links that can't be reused by the wrong person.
4Audit records
The audit controls standard asks for "mechanisms that record and examine activity in information systems that contain or use electronic protected health information" (164.312(b)). For a video platform, that means a log of sign-ins, who joined which session and when, and changes to account settings. Ask whether you can see the log yourself or must request it, and how long it is kept.
5A clear answer on recordings, transcripts and chat
HHS's audio-only guidance names the risk directly: PHI "created or stored as a result of a telehealth session" (it gives session recordings and transcripts as examples) "could be accessed by an unauthorized third party." Before your first session, know whether the platform records, transcribes or saves chat, whether those features are on by default, where the files go (the vendor's cloud, your computer, a linked drive), who can open them, how long they're kept, and whether the BAA covers them. Many therapists don't record sessions at all. If you do, get written consent and check your state's recording law.
What stays your job
Know whether you're a covered entity. HIPAA covers health care providers "only if they transmit any information in an electronic form in connection with a transaction for which HHS has adopted a standard," such as billing insurance electronically (HHS, Covered Entities and Business Associates). A therapist who sees only private-pay clients, with nobody billing insurance for them, may not be one. Privacy still isn't optional: state law applies, and the ACA Code of Ethics asks counselors to "use current encryption standards within their websites and/or technology-based communications that meet applicable legal requirements" (H.2.d). Many therapists follow HIPAA either way. If you aren't sure, ask a healthcare attorney.
Do a risk analysis. It is a required part of the Security Rule: "an accurate and thorough assessment of the potential risks and vulnerabilities" to electronic PHI (45 CFR 164.308). HHS describes the rule as "flexible, scalable, and technology neutral" (Summary of the HIPAA Security Rule), so a solo practice's analysis can be short. HHS and ONC publish a Security Risk Assessment Tool for small practices.
Handle the parts no platform can. A private room, a locked device, a telehealth consent, and a plan for emergencies. These come up again in the checklist below.
The COVID-era flexibility ended in 2023
In March 2020, HHS's Office for Civil Rights (OCR) said it would not penalize good-faith telehealth through "any non-public facing remote communication product," naming Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, Zoom and Skype. Public-facing apps such as Facebook Live, Twitch and TikTok were never allowed. The notice also listed vendors that said they would sign a BAA, with the caution that "OCR has not reviewed the BAAs offered by these vendors" (Notification of Enforcement Discretion for Telehealth).
That notice expired at 11:59 pm on May 11, 2023, with the end of the COVID-19 public health emergency. OCR gave a 90-day transition period that ended at 11:59 p.m. on August 9, 2023 (HHS press release, April 11, 2023). If you started seeing clients online in 2020 with a tool you never signed a BAA for, that flexibility is over. Guides written in 2020 still turn up in search, and they describe rules that no longer apply.
A checklist for comparing telehealth platforms
Use this on every option, including the one you already have. A "no" isn't always a dealbreaker, but you want to find it before a client is waiting.
The agreement
Security
The client's experience
Your clinical and legal workflow
Questions to send a vendor before you sign up
A sales page can say "HIPAA compliant" without saying what that covers. A short email gets you the details in writing. Copy this, fill in the brackets, and keep the reply with your records.
Run a test session before your first client
A demo shows you the platform at its best. A test session shows you what your clients will meet. Use a second email address and invented names, never a real client's, and give yourself 15 minutes.
- Create or book a session the way a client would receive it, and send it to your second address.
- Join as the client from a phone, on mobile data rather than your office Wi-Fi.
- Check what the client sees while waiting, and that they can't get in until you admit them.
- Switch the phone to airplane mode for a few seconds in the middle of the call, then rejoin. Time how long it takes.
- If there's a phone fallback, try it.
- After the session ends, open the same link again. It should not put you back in a live room.
- Look for anything the session left behind: chat, files, a recording, a transcript, a calendar entry with a name in it.
- Sign out, sign back in with two-step sign-in, and check that the activity log shows the test.
- Write down what you found, using the record below.
Keep a record of what you compared and why you chose. HIPAA asks you to keep Security Rule documentation, including your risk analysis, for six years from when it was created or last in effect (45 CFR 164.316), so this belongs in the same folder.
Three kinds of telehealth platforms
Most options fall into one of three groups. They differ less in whether a BAA is available than in how much of your practice they hold.
General video tools with a BAA
These are video meeting tools from large office and communication suites. Each offers a BAA, on its own terms.
- Google Workspace (Google Meet).Google lists Google Meet among the Workspace services covered by its BAA (Google). The BAA is made available "for electronic acceptance via their Admin console," and Google is plain about the alternative: "Customers who have not signed a BAA with Google must not use PHI in Google Workspace or Cloud Identity services" (Google Workspace help). Our guide to whether Google Meet is HIPAA compliant walks through the settings, and the Gmail guide covers the email side, including why a personal Gmail account is different.
- Zoom.Zoom's healthcare page says "Zoom for Healthcare helps enable customers' HIPAA compliance by executing a Business Associate Agreement (BAA)" (Zoom). A Zoom post from March 2021 described an online process for small US practices to accept a BAA on a Pro plan, covering up to nine licenses, with larger accounts going through sales (Zoom blog). Processes change, so confirm the current one with Zoom. Our guide to whether Zoom is HIPAA compliant covers its BAA steps and settings.
- Microsoft 365 (Microsoft Teams).Microsoft says its HIPAA BAA "is available through the Microsoft Online Services Data Protection Addendum by default to all customers who are covered entities or business associates under HIPAA," and lists Microsoft Teams among the in-scope services (Microsoft). Our guide to whether Microsoft Teams is HIPAA compliant covers the plans and settings.
Where they fit: you already run your email and calendar on the suite, and you're comfortable managing settings. What you still manage: meeting links and invites, the settings for each meeting, and a separate booking system and note system, each needing its own BAA.
Dedicated telehealth tools
These are built for one-to-one clinical visits rather than office meetings, often around a virtual waiting room and a link the client opens. Two that appear in many comparisons, both on HHS's 2020 vendor list:
- doxy.me.Its help center explains that a provider generates a BAA in account settings (Settings, then the BAA tab), that the BAA on its non-Clinic accounts "is meant for individual providers only," and that practices with several providers use a Clinic BAA (doxy.me help center).
- VSee.Its help center says: "To receive a signed BAA, please send us an email at [email protected]" (VSee help).
Where they fit: you want a simple, focused video room and already have booking and notes elsewhere. What you still manage: getting each client the right link at the right time, and moving session details into your notes, unless the tool connects to your other software.
All-in-one practice software
These put booking, video sessions, notes, forms and often payments in one account under one vendor's BAA. The questions change a little:
- Does the BAA cover every part you'll use, including the video?
- Does the vendor run its own video, or use another company's? If another company, is it bound as a subcontractor?
- Can you export your records and notes if you ever leave?
Where they fit: you're starting a practice, or you're tired of copying the same details between three tools. Our guide to starting as a private practice therapist covers the other setup decisions. What you still manage: your own settings, your risk analysis, and the parts of the practice you keep outside the software.
Which kind fits your practice
- A small caseload, and your practice already runs on Google Workspace or Microsoft 365:a general tool under that suite's BAA is the smallest change.
- A booking system and notes you like, and a need for video only:a dedicated telehealth tool.
- A new practice, or a wish to stop juggling tools:all-in-one practice software.
- Any of the above:run the checklist and the test session before a client depends on it.
How video sessions work in TranqBay
TranqBay is practice software for therapists in private practice: a practice website, online booking, video sessions, session notes and client forms in one place. Here is how it handles the points in the checklist.
- A BAA in place.Video sessions are HIPAA-ready, and TranqBay signs a Business Associate Agreement with therapists who are covered entities. It applies automatically when you accept TranqBay's Terms of Service, so there's no separate document to sign. You can read TranqBay's Business Associate Agreement before you decide anything.
- End-to-end encrypted video.TranqBay's video sessions are end-to-end encrypted, and its Business Associate Agreement says so in writing.
- Clients join from the booking.When a client books through your booking page, the video session belongs to that booking, and the client joins from it. There's no meeting link to create, paste into an invite or reuse between clients.
- The note belongs to the session.You write the session note on the session itself, in BIRP, DAP, SOAP, GIRP or a blank note. Structured formats are part of the advanced note templates, which some plans include. Our DAP notes examples show what a finished note looks like.
- Consent before the first session.The form library has ready-made templates you can send a client for a session, including telehealth consent, consent to treat, intake forms, release of information, the PHQ-9 and the GAD-7. The client fills them in online and the answers wait with the session. Forms aren't scored automatically; the PHQ-9 scoring tool can help with that.
To see how the pieces fit before you set anything up, the sessions section of the practice site follows one session from the booking to the video call to the note. Two points carry over from the checklist. TranqBay's BAA covers TranqBay, so if you still email clients from another account, that email provider needs its own BAA with you. And licensing, the client's location and your emergency plan stay your responsibility on any platform.
Frequently asked questions about HIPAA compliant telehealth platforms
What makes a telehealth platform HIPAA compliant?
A signed BAA with the vendor, encryption of video in transit and of anything stored, access controls such as unique logins and two-step sign-in, audit records, and clear handling of recordings, transcripts and chat. Then your part: a risk analysis, careful settings, a private space and consent.
Is there a HIPAA certification for video platforms?
No. HHS has no certification program for HIPAA compliance, and Google and Microsoft both say so in their own documentation. A "HIPAA certified" badge is marketing. Ask for the BAA instead.
Can I use FaceTime or an ordinary video account for therapy?
Not with a covered practice's clients unless the vendor signs a BAA with you. The 2020 flexibility that allowed apps like FaceTime and Skype without a BAA is over: its 90-day transition period closed on August 9, 2023. Our guide to whether FaceTime is HIPAA compliant explains why in detail.
Do I need a BAA if I only see private-pay clients?
Possibly not under HIPAA, if you never send standard electronic transactions and nobody sends them for you. State law, your licensing board and your professional code still apply, and you may start billing insurance later. Many therapists choose a platform with a BAA either way. Ask a healthcare attorney before deciding you're outside HIPAA.
Does HIPAA require end-to-end encryption?
No. The current Security Rule treats encryption as addressable and names no method. Encryption in transit is the reasonable baseline for internet video. HHS's proposed update would make encryption required, but it hasn't been finalized as of this writing.
Do clients need to download an app?
It depends on the platform. Some open in a phone or computer browser, others need an app, and some offer both. Check it in your test session and tell clients what to expect before the first visit.
Can I see a client who is in another state?
Generally only if you're licensed, or hold a compact privilege, in the state where the client is during the session. Some states have temporary practice or telehealth registration rules. Check with that state's board, and confirm the client's location at the start of every session.
Should I record telehealth sessions?
Many therapists don't. If you do, get the client's written consent, check your state's recording law, and know where the file is stored, who can open it and when it's deleted. The BAA should cover wherever it lives.
What is the best telehealth platform for therapists?
The one that signs a BAA for the plan you'd use, gives you the safeguards in the checklist, works for your clients on the devices they have, and fits how you book sessions and write notes. That answer differs between a solo private-pay practice and a group that bills insurance, which is why this guide doesn't rank products.
Before you choose a platform
Get the BAA first, then check the settings, run the test session, and write down what you found and why you chose. Most of the risk with telehealth sits in a few places: the agreement, the link, the recording and the client's location.
If you'd like booking, video sessions and notes in one place under one BAA, see how TranqBay works for private practice: you can look at a practice website template and the booking page your clients would use. If you're deciding whether to join, this page explains how joining TranqBay works.
Sources
HHS 11Federal 1Regulations 7Google 2zoom.com 2learn.microsoft.com 1helpcenter.doxy.me 1help.vsee.com 1Associations 1Compacts 3
U.S. Department of Health and Human Services11
- 1Telehealth.HHS.gov: HIPAA Rules for telehealth technologytelehealth.hhs.govhttps://telehealth.hhs.gov/providers/telehealth-policy/hipaa-for-telehealth-technology
- 2Notification of Enforcement Discretion for Telehealth Remote Communications (2020)hhs.govhttps://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html
- 3OCR announces expiration of COVID-19 public health emergency HIPAA notifications of enforcement discretion (April 11, 2023)hhs.govhttps://www.hhs.gov/about/news/2023/04/11/hhs-office-for-civil-rights-announces-expiration-covid-19-public-health-emergency-hipaa-notifications-enforcement-discretion.html
- 4Guidance on HIPAA and audio-only telehealthhhs.govhttps://www.hhs.gov/hipaa/for-professionals/privacy/guidance/hipaa-audio-telehealth/index.html
- 5Resource for health care providers on educating patients about telehealth privacy and security riskshhs.govhttps://www.hhs.gov/hipaa/for-professionals/privacy/guidance/resource-health-care-providers-educating-patients/index.html
- 6Covered Entities and Business Associateshhs.govhttps://www.hhs.gov/hipaa/for-professionals/covered-entities/index.html
- 7Business Associate Contracts (sample provisions)hhs.govhttps://www.hhs.gov/hipaa/for-professionals/covered-entities/sample-business-associate-agreement-provisions/index.html
- 8Summary of the HIPAA Security Rulehhs.govhttps://www.hhs.gov/hipaa/for-professionals/security/laws-regulations/index.html
- 9Telehealth.HHS.gov: Licensing across state linestelehealth.hhs.govhttps://telehealth.hhs.gov/licensure/licensing-across-state-lines
- 10Telehealth.HHS.gov: Creating an emergency plan for telebehavioral healthtelehealth.hhs.govhttps://telehealth.hhs.gov/providers/best-practice-guides/telehealth-for-behavioral-health/preparing-patients-for-telebehavioral-health/creating-a-telehealth-emergency-plan
- 11Telehealth.HHS.gov: Obtaining informed consent for telebehavioral healthtelehealth.hhs.govhttps://telehealth.hhs.gov/providers/best-practice-guides/telehealth-for-behavioral-health/preparing-patients-for-telebehavioral-health/informed-consent-for-telebehavioral-health
Other federal agencies1
Laws and regulations7
- 1345 CFR 164.306, security standards and addressable specificationsecfr.govhttps://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-C/section-164.306
- 1445 CFR 164.308, administrative safeguardsecfr.govhttps://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-C/section-164.308
- 1545 CFR 164.312, technical safeguardsecfr.govhttps://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-C/section-164.312
- 1645 CFR 164.316, documentationecfr.govhttps://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-C/section-164.316
- 1745 CFR 164.410, notification by a business associateecfr.govhttps://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-D/section-164.410
- 1845 CFR 164.504, business associate contractsecfr.govhttps://www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-E/section-164.504
- 19Federal Register: HIPAA Security Rule to Strengthen the Cybersecurity of ePHI (proposed rule, January 6, 2025)federalregister.govhttps://www.federalregister.gov/documents/2025/01/06/2024-30983/hipaa-security-rule-to-strengthen-the-cybersecurity-of-electronic-protected-health-information
Google2
- 20HIPAA compliance on Google Cloud and Google Workspacedocs.cloud.google.comhttps://docs.cloud.google.com/docs/security/compliance/hipaa
- 21HIPAA Compliance with Google Workspace and Cloud Identityknowledge.workspace.google.comhttps://knowledge.workspace.google.com/admin/compliance/hipaa-compliance-with-google-workspace-and-cloud-identity